The Court dismissed Trump's Counterclaim against Jean Carroll because the jury in that case found that Trump raped Carroll with his fingers.
Trump's counterclaim alleged defamation when Carroll observed that Trump is a rapist. The defamation claim was based on the jury not finding that he "raped" her within the meaning of New York's penal law which requires use of a penis to commit the crime as defined in that statute. The Court recognized that the jury concluded that Trump raped (within the word's common usage) Carroll, albeit not with his penis. Therefore a defamation claim for calling him a rapist must fail.
https://twitter.com/kyledcheney/status/1688582423309623296